Pre-submittal finding closure
Closing coverage gaps against the certification basis before submittal
This work finds requirements in the certification basis that the planned compliance data simply does not address, and closes each one before submittal. An engineer reads the basis against the compliance plan, identifies every basis item with no planned means of compliance and no assigned evidence, and maps it to a method and an owner. It runs during a pre-submittal review, when the basis is fixed but the compliance data may not yet cover all of it. You receive a closure brief listing the uncovered basis requirements, an evidence request list for the compliance data to be produced, and a disposition package showing full basis coverage with an owner on each line.
When this review is needed
- A basis requirement appears in the applicable regulations but never shows up in the compliance plan.
- A special condition or issue paper was added to the basis after the plan was written and was never folded in.
- An amendment changed the applicable rule and the plan still addresses the earlier version.
- The plan covers most of the basis but a handful of items have no method and no evidence owner.
The problem
The certification basis and the compliance plan are built by different people at different times, and they drift apart. A special condition arrives after the plan is drafted, an amendment shifts the applicable paragraph, a requirement is assumed to be someone else's scope and falls between two teams. Each uncovered item is invisible in the compliance matrix because the matrix only lists what the plan chose to address. Finding the gaps means reading the basis directly and asking, for every requirement, whether anything in the plan actually answers it.
What gets reviewed
- The full certification basis, including special conditions and issue papers, listed against the compliance plan
- Each basis requirement checked for a planned means of compliance
- Amendment level of each applicable rule confirmed against what the plan addresses
- Requirements assumed to sit in another team's scope surfaced and assigned
- A means of compliance and an evidence owner proposed for each uncovered item
- A basis coverage view showing every requirement mapped to a method and an owner
What gets validated
- Every requirement in the certification basis maps to at least one planned means of compliance
- Special conditions and issue papers added to the basis appear in the compliance plan
- The amendment level the plan addresses matches the applicable rule on the basis
- No basis requirement is left unassigned on the assumption that another team owns it
- Each newly covered item names both the method and the party responsible for the evidence
Evidence normally required
- The certification basis, including special conditions and issue papers
- The compliance plan or certification plan with its planned means of compliance
- The applicable regulations at their governing amendment level
- The compliance matrix as it stands, for cross-check against the plan
- The finding text identifying the suspected coverage gaps
Common discrepancies
- A special condition added late to the basis that the compliance plan never addresses
- An amendment that moved the applicable rule while the plan still answers the prior version
- A requirement that two teams each assumed the other would cover, so neither did
- A basis paragraph with a planned method but no named evidence owner
What is at stake
A basis requirement with no compliance data is a hole the reviewer will find, and it reopens the compliance planning conversation at the worst possible moment. Beyond schedule, an uncovered special condition or amendment can require work that was never scoped or budgeted, and discovering it at the authority rather than in-house means negotiating the fix under the reviewer's eye instead of on the applicant's terms.
Move from findings to resolution
Identify the missing data behind the finding.
How the work runs
Enumerate the basis
List every requirement in the basis, including special conditions and issue papers at their current amendment.
Map to the plan
Check each basis requirement for a planned means of compliance in the compliance plan.
Assign the uncovered
Propose a method and an evidence owner for every requirement the plan does not address.
Package coverage
Write the closure brief, list the compliance data to produce, and deliver a full coverage view.
What the buyer receives
- A closure brief listing each uncovered basis requirement and the method assigned to it
- An evidence request list for the compliance data now scheduled to be produced
- A reviewer-ready disposition package showing full basis coverage with an owner per line
Who uses the output
- Certification engineers closing the plan against the basis before submittal
- Program managers scoping and scheduling the newly identified compliance work
- Compliance leads assigning method and evidence ownership across the team
How the work fits into the transaction or program
Basis coverage closure runs early enough in a pre-submittal review that new compliance work can still be scheduled, because an uncovered requirement often means real work rather than a missing citation. It underpins the compliance matrix and the verification trace: those are only complete if the plan they express covers the whole basis. Closing the coverage gap keeps later findings from resting on a plan that was incomplete from the start.
Start with a single asset
Confirm each requirement maps to substantiating evidence.
Jurisdiction-specific considerations
The certification basis itself differs between an FAA project and an EASA one, from the applicable rules to how special conditions and issue papers are raised, so coverage is assessed against the basis the reviewing authority has actually established rather than a merged rule set.
Regulatory limits
This work identifies uncovered basis requirements and proposes a method and owner for each. It does not establish the certification basis, negotiate special conditions, approve the compliance plan, or make any compliance finding, which rest with the applicant and the authority.
What this review does not cover
- Establishing or amending the certification basis or its special conditions
- Producing the compliance data that a newly identified requirement needs
- Making the compliance finding on any basis requirement
Specific to this review
- Coverage gaps are invisible in the compliance matrix, because the matrix lists only what the plan chose to address, so they can only be found by reading the basis directly.
- A late special condition is the most common source of an uncovered requirement, since it arrives after the plan is already drafted.
- Requirements that fall between two teams are the hardest to catch, because each team's own matrix looks complete from where it sits.
Sources
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
How is this different from checking the compliance matrix?
The matrix shows what the plan decided to cover, so a requirement it omits is simply absent, not flagged. This closure works from the certification basis itself and asks, for every requirement, whether the plan answers it, which is the only way an omitted item surfaces before the reviewer finds it.
Relevant glossary terms
Related pages
Where this fits
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